UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION WASHINGTON, DC 

Regulatory Docket No. _______________ 

PETITION FOR EXEMPTION OF: 

ALEXIS F. COVO dba/ALEX COVO PHOTO

SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

 SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF 3D ROBOTICS SOLO UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on Nov 5th, 2015 

Alex Covo Photo 

Alexis F. Covo

Owner

263 1st Ave Apt 7 

New York, NY 10003 

Tel:(917)500-4300 

Email: info@alexandiggy.com 

Alexis F. Covo - 333 Exemption Petition Page 1 of 24
Table of Contents

GLOSSARY OF ABBREVIATIONS 3 

EXHIBIT LIST 4 

I. PUBLISHED SUMMARY 5 

Expeditious Summary Grant Approval Request 6 

II. PETITIONER’S CONTACT & BACKGROUND INFORMATION 6 

III. PROPOSED OPERATIONS 7 

IV. THE UAS 8 

V. PIC REQUIREMENTS 9 

VI. FLIGHT OPERATIONS 11 

VII. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 12 

VIII. PROPOSED CONDITIONS OF THE EXEMPTION 13 

IX. PRIVACY 17 

X. PUBLIC INTEREST AND SAFETY 17 

XI. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 18 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness. 19 

14 C.F.R. §91.119: Minimum safe altitudes 19 

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance21

Inspections 21 

Appendix A-1: 21 

Alexis F. Covo - 333 Exemption Petition Page 2 of 24
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

PO Payload Operator 

SECTION 33 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VO Visual Observer 

VTOL Vertical Takeoff and Landing

Alexis F. Covo - 333 Exemption Petition Page 3 of 24
EXHIBIT LIST

Exhibit_1_Alexis_F_Covo_Pre-flight_Checklist.pdf 

Exhibit_2_Solo_Manual_v4_07_07_15.pdf 

Flight_Log.pdf 

APPENDIX A-D Motion Picture and Television Operation Manual V1

Alexis F. Covo - 333 Exemption Petition Page 4 of 24
I. PUBLISHED SUMMARY

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, ALEXIS F. COVO (Petitioner) seeks exemption from the following rules: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Alexis F. Covo (“Petitioner”) Operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to offer on-demand commercial UAS operations for a host of 

industries and applications and to perform the purposes listed below, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation 

of its sUAV’s/UAS, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA in an exemption granted under either 

Section 333 or Section 49 U.S.C. §44701(f)

The requested exemption should be granted because operation of a small UAS weighing 

approximately 3.3 lb. (1.5 kg.), inclusive of battery and payload, conducted in the strict 

conditions outlined below, will provide an equivalent level of safety, while still allowing 

commercial operations.

The request for this exemption is in the Public Interest as the lightweight aircraft covered by the 

exemption are far safer than conventional operations conducted with helicopters and fixed-wing 

aircraft weighing thousands of pounds and carrying highly flammable fuel, and operating in 

close proximity to the ground and people. The seven factors Congress directed the FAA to 

consider when approving Section 333 exemption petitions - size, weight, speed, operational 

capability, proximity to airports, proximity to populated areas, and operation within visual line of 

sight – each support the request. In particular, the aircraft are small, and will operate at slow 

speeds, and close to the ground. The substantial increase of safety and decrease of risk to human 

life, coupled with the low risk use of UAs to conduct these operations, benefit the public and 

way heavily in favor of providing an exemption to the Petitioner, whose operations pose no 

potential hazard to the national airspace system, general public, or present any threat to national 

security.

Alexis F. Covo - 333 Exemption Petition Page 5 of 24
Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this application. 

Petitioner has provided in a confidential document attachment labeled as petitioner proprietary 

information, specific exemption numbers whereby the FAA has already granted a previous 

exemption similar or identical to each and every request, herein.

The petitioner requests the agency issue a summary grant process for this application. 

Petitioner has provided a table (APPENDIX A-1) of FAA exemptions granted for similar or 

identical petition for exemption.

II. PETITIONER’S CONTACT & BACKGROUND INFORMATION

“Alex Covo Photo” 

owner/ALEXIS F. COVO 

263 1st Ave Apt 7 

New York, NY 10003 

917-500-4300 

alex@alexcovo.com 

Alexis F. Covo (Petitioner) is an internationally recognized and published photographer. He has 

worked professionally/commercially in the United States and throughout Europe. Services 

offered to his commercial and editorial clients include photography, videography and 

cinematography. The petitioner is also a member of the Academy of Model Aeronautics, open 

member number #1079292 in good standing. The Petitioner is seeking a Section 333 exemption 

in order to continue to remain competitive and provide his clients with services in the field of 

photography, videography and cinematography. 

Alexis F. Covo - 333 Exemption Petition Page 6 of 24
III. PROPOSED OPERATIONS

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability of the particular UAS. 

Petitioner proposes using the 3DR Solo. The proposed system has the inherent advantage of 

being small in size and battery-operated therefore do not carry flammable fuel, this 

significantly reduces any potential damage in the event of a mishap. 

This exemption request, once granted would allow the petitioner to operate a small 

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct aerial video 

and photography for public and private use including television, public events, and 

cinematography live feed and live news gathering, motion picture production, closed set 

filming.* 

Petitioner will operate the proposed UAS below 400 feet AGL, at speeds less than that 

recommended by the manufacturer, and at all times less than 50 knots. Operations will only 

be conducted in during daylight hours, in uncontrolled airspace, unless specific permission 

is granted by the controlling agency, and within visual line of sight of the operator.

* SEE SUPPORTING DOCUMENTATION: APPENDIX A-D MOTION PICTURE AND 

TELEVISION OPERATION MANUAL V1, EXHIBIT 1 PREFLIGHT CHECKLIST, 

EXHIBIT 2 USER MANUAL.

Alexis F. Covo - 333 Exemption Petition Page 7 of 24
IV. THE UAS

The UAS that will be operated with this exemption has been previously approved in other 

Section 333 exemption requests. The FAA has previously approved the 3DR Solo in 

Exemption Nos. 11335A, 11778A, 11832, 11935. An analysis of these criteria 

demonstrates that the purposed UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, 

than a conventional aircraft (fixed or helicopter) operating with an airworthiness certificate 

without the restrictions and conditions proposed. The requested exemption will permit 

petitioner to operate the 3DR Solo commercially.

THE UAS HAS THE FOLLOWING SPECIFICATIONS OR EQUIVALENT

Airframe: 3DR Solo 

Control system: 3DR Pixhawk 2 autopilot system, which contains the gyroscope, accelerometer/magnetometer, and barometer. Maximum speed: 48 knots

Weight, inclusive of battery and technical payload: 3.3 lbs (1.5kg) 

Transmitter (Tx): 2.4 Ghz 3DR Solo Controller

Receiver (Rx): internal to the flight control system Motors: 880 KV motors

Propellers: 10 in. x 4.5 in.

Combined data and video link: 3DR Link secure Wi-Fi Gimbal: 3-axis Solo

Batteries: Lithium polymer, 5200 mAh, 14.8 Vdc

Telemetry display: 3DR Solo App using the APM: Copter flight control software 

Automatic return to home procedure: If the signal between the UA and the controller is

lost during flight, the Solo will: (1) rise to 98 ft. AGL (30 m) or maintain current altitude if 

above 98 feet; (2) travel horizontally to the launch point and hover for 5 seconds; and (3)

land.

Please refer to the Exhibit 2 for more information regarding this UA and its flight 

control system.

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V. PIC REQUIREMENTS

Petitioner respectfully submits that the operator requirements should take into account the advanced 

internal navigation and autopilot systems of the proposed UAS. The 3DR system has a high degree of 

control and is extremely stable even in high wind environments. 3DR incorporate various built-in 

capabilities that limit the potential for operations outside of the aircraft capability. 

The pilot in charge (PIC) is solely responsible for the safe operation of the UAS. The Petitioner will only 

use PIC’s who possess, at minimum, a sport pilot license and either a U.S. driver’s license or a third-class 

medical certificate. Petitioner will also ensure that all PICs comply with governmental and manufacturer 

training requirements, and have been deemed safe and proficient by the chief pilot.

Advanced sUAV’s has a navigation and control system and auto-pilot that allows it to execute very 

accurate pre-programed flights. Flights are pre-programmed with GPS waypoint to establish perimeters 

beyond which the aircraft will not operate. Flights under auto-pilot are not directed by positive manual 

input, but through pre- programmed flight parameters that are executed by the auto-pilot. In the case of 

unplanned events, the Operator inputs preprogrammed evasive maneuvers from the control unit, and the 

autopilot executes those maneuvers. Pre-programmed Operator interventions include: initiation of holding 

at present position; suspension of mission; fly back to launch point; abort mission and land immediately; 

and emergency power cut off and land (flight termination system). Additional automated safety functions 

and safety enhancing features of the Advanced sUAV’s may include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing, 

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing, 

3) Ifthe auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored, 

execute a return to home and land, 

4) Redundant “kill switches” that enable completely shutting the aircraft down in

flight in the event of a loss of control or un-commanded deviation fromthe 

flight path, 

5) The aircraft, weighs less than 55 lbs., fully loaded, 

6) Themotors are driven by pulsewidthmodulated signals, not analog signals, 

7) The aircraft will operate for the Purposes at no more than 30 mph (while 

imaging) nor above 200 feet above the structure (imaging altitude) or a 

maximumof400feetAGL.

Petitioner additionally asks that the exemption be issued without the requirement for a visual

observer.As set forth herein, an equivalent level of safety is provided by the size, speed and 

control capabilities of the aircraft, as well as the operational procedures that will be applicable to

all flight hereunder. These obviate the need for the visual observer.

Alexis F. Covo - 333 Exemption Petition Page 9 of 24
A qualified Pilot In Command (PIC)/Operator holding at least a sport pilot certificate issued but 

the FAAwill be operating the aircraft, always within line of sight. He or she will walk and follow the

aircraft around an area so that while it is flying its pre-programed and at times, manual flight path,

the UAS will always be directly in his or her line of sight. The Operator will not be distracted by

viewing the pictures taken during the flight. Rather, once the sUAV is launched, the Operator’s only

duty will be to watch the flight of the UAS and intervene to address flight path deviations or other

issues that arise during the flight. The functions that an observer performs where the aircraft is

flown at long distances from the launch area will not be necessary as the Operator will always

have the aircraft in his or her direct sight. The observer also will not be necessary because the 

Operator will conduct a pre-flight inspection of the area, will and if needed, cordon off the area 

and will perform frequent visual scans of the area while the vehicle is operating.

Petitioner again notes that the NPRM does not require the use of a visual observer. Given the 

clear direction in Section 333 of the Reform Act; the authority contained in the Federal Aviation

Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and 

the significant public benefit, including enhanced safety, reduction in environmental impacts, 

including reduced emissions associated with allowing battery powered sUAV’s for these 

functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots having at

least a private pilot license, the grant of the requested exemptions is in the public interest.

Alexis F. Covo - 333 Exemption Petition Page 10 of 24
VI. FLIGHT OPERATIONS

The UA will be used for aerial photography, aerial cinematography and videography for the 

television and motion picture industry for closed set filming, small events and activities, 

individual commercial, public, and residential properties in Class G airspace (unless otherwise 

prescribed by an ATO-issued COA) under 400 feet above ground level (“AGL”) and under 

controlled conditions over restricted property. Petitioner will work with the local FSDO when 

planning operations. Petitioner will ensure that the exemption does not adversely affect safety 

and will operate at a level of safety at least equal to existing rules by operating with the 

following limitations and conditions.

1. All operations will strictly adhere to manufactures owners, operators and maintenance 

manual. 

2. All operations will occur in class G airspace, unless specifically authorized by the 

controlling authority. 

3. All operations will be conducted during daylight hours. 

4. All operations will occur below 400 feet AGL. 

5. All operations will be conducted and visual meteorological conditions with visibility of at 

least three nautical miles. 

6. All operations will be conducted with at least 500 feet below clouds and with a horizontal 

separation of at least 2000 feet. 

7. At no time will the operator allow the aircraft within 500 feet of nonparticipating person, 

structure, or vehicle. 

8. Preflight operations will be conducted in accordance with the manufacturer's 

recommendation and preflight checklist. 

9. All maintenance will be conducted in accordance with manufacturers recommendations 

and documented in the aircraft logbook 

Please refer to the following exhibits for more information regarding flight operations: 

- Exhibit 1: ALEXIS_F_COVO_Pre-flight_Checklist.pdf

- Exhibit 2: Exhibit_5_Solo_Manual_v4_07_07_15.pdf

 Section 1.4: Operating Parameters 

Section 2: Setup

Section 3.4: Flight School Section 

3.7: Home Position

Section 3.9: Emergency Procedures 

Section 4.1: Preflight

Section 4: Landing

Section 9: Maintenance

- APPENDIX A-D Motion Picture and Television Operation Manual V1.pdf 

Alexis F. Covo - 333 Exemption Petition Page 11 of 24
The specific conditions of the proposed exemption that relate to flight operations are 

numbers 11-12, 17-25, and 32-35 in Section VIII below. Each has been accepted or 

imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

VII. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Petitioner proposes that the exemption apply to UAs that have the characteristics and that 

operate with the limitations proposed herein. These limitations provide for a level of 

safety at least equivalent to or higher than manned aircraft operations under the current 

regulatory structure. Section VIII below identifies the limitations and conditions to which 

petitioner agrees to be bound when conducting commercial operations under a grant of 

this petition. Appendix A-1 contains a matrix connecting (i) the specific proposed 

condition with (ii) the FAR provision for which it provides an equivalent level of 

safety and (iii) one or more recent Section 333 exemption grants in which the FAA 

recognized this equivalent level ofsafe (Exemptions 11136, 11138, 11172, 11174 and 11177, 

11062, 11109, 11112, and 11213 and asrecent as 11857).

Approval of the commercial operations outlined in this petition presents no national 

security issue. The PIC will possess, at minimum, a sport pilot’s certificate. Therefore, 

he or she will have been subject to security screenings by the Department of Homeland 

Security. 

Alexis F. Covo - 333 Exemption Petition Page 12 of 24
VIII. PROPOSED CONDITIONS OF THE EXEMPTION

1. The UAs, including battery and technical payload will weigh no more than 

approximately 3.3 lb. (1.5 kg.). 

2. UA operations under this exemption will be limited for the purpose of photography, 

videography, cinematography, closed set motion picture and television filming, and 

will be limited to conducting operations in Class G airspace nationwide, unless 

otherwise prescribed by an ATO issued COA. 

3. Flights will be operated within line of sight of the PIC and a VO. 

4. Flights will be operated at an altitude of no more than 400 feet AGL, as indicated by 

the procedures specified in the operating documents. All altitudes reported to ATC 

must be in feet AGL. 

5. The UA will not be flown at an indicated airspeed exceeding 48 knots. 

6. Minimum flight crew for each operation will consist of the UA PIC and a VO. 

7. The PIC will have at minimum a sport pilot license and either a U.S. driver’s license 

or a third class medical certificate. 

8. The petitioner will not permit any PIC to operate unless the PIC meets its 

qualification criteria and demonstrates the ability to safely operate the UA in a 

manner consistent with how the UA will be operated under this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. PIC qualification flight hours and currency 

will be logged in a manner consistent with 14 CFR §61.51(b). A record of the PIC 

training will be documented and made available upon request by the Administrator. 

Training operations will only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations will be considered nonparticipants, and the PIC will operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

9. When a VO is necessary, they will not perform any other duties beyond assisting the 

PIC with seeing and avoiding other air traffic and other ground based obstacles/

obstructions, and will not be permitted to operate the camera or other instruments. 

10. The PIC will be designated before the flight and will not be allowed to transfer his or 

her designation for the duration of the flight. When necessary, the PIC will ensure that 

the VO can perform the functions prescribed in these conditions and the operating 

documents.

Alexis F. Covo - 333 Exemption Petition Page 13 of 24
11. A briefing will be conducted in regard to the planned UA operations prior to each 

day’s activities. It will be mandatory that all personnel who will be performing duties 

in connection with the operations be present for this briefing. 

12. Prior to each flight, the PIC will inspect the UA, including the Ground Control 

Station, to ensure it is in a condition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UA, the PIC will not operate the UA 

until the necessary maintenance has been performed and the UA is found to be in a 

condition for safe flight. All maintenance and alterations will be properly documented 

in the aircraft records. 

13. Petitioner will conduct a functional flight test on any UA that has undergone 

maintenance or alterations that affect the UA operation or flight characteristics, e.g. 

replacement of a flight critical component. The PIC who conducts the functional test 

flight will make an entry in the aircraft records. 

14. The petitioner will carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the UA manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements set forth 

in the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts will be noted in the aircraft records, including 

total time in service, description of work accomplished, and the signature of the 

authorized person returning the UA to service. The authorized person will make an 

entry in the aircraft record of the corrective action taken against discrepancies 

discovered between inspections. 

15. The UA will be operated within visual line of sight (VLOS) of the PIC and VO at all 

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses. PIC and VO will at all times be able to communicate 

verbally. They will not be permitted to use electronic messaging or texting to 

communicate during flight operations. 

16. The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and prepare to land with at least 25% battery power remaining. 

17. Actual total flight time for each operational flight will result in no less than a 25% 

battery reserve. 

18. The UA will have the capability to abort a flight in case of unexpected obstacles or 

emergencies.

Alexis F. Covo - 333 Exemption Petition Page 14 of 24
19. The UA will be programmed so that if it loses communications or loses its GPS 

signal, it will return to a pre-determined location within the planned operating area 

and land or be recovered in accordance with the operating documents. 

20. If the UA and its radio control link disconnect during flight, the system’s failsafe 

protection will be triggered and the multirotor will return to home and land 

automatically, rather than flying off uncontrollably or landing at an unknown location. 

21. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be 

maintained and available to the PIC at the Ground Control Station of the UA any time 

the UA is operating. These documents will be made available to the Administrator or 

any law enforcement official upon request. If a discrepancy exists between the 

conditions and limitations in the exemption grant and the procedures outlined in the 

operating documents, the grant conditions and limitations will take precedence and 

will be followed. Otherwise, the petitioner will follow the procedures outlined in its 

operating documents. If it updates or revises its operating documents, it will present 

updated and revised documents to the Administrator upon request. If the petitioner 

determines that any update or revision would affect the basis upon which the FAA 

granted the exemption, then the Petitioner will petition for an amendment to the grant 

of exemption. 

22. Petitioner will obtain written and/or oral permission from the landowners/authorized 

agents of the landowners over which flights will be conducted. 

23. Petitioner will obtain all required permissions and permits from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

24. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). Flights 

will not be conducted under special visual flight rules (SVFR). 

25. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. Petitioner will request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. All operations will 

be conducted in accordance with airspace requirements in the ATO issued COA, 

including class of airspace, altitude level and potential transponder requirements.

Alexis F. Covo - 333 Exemption Petition Page 15 of 24
26. The UA will not be operated within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management has been obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. Any letter of 

agreement with the airport management will be made available to the Administrator 

upon request. 

27. The UA will not be operated less than 500 feet below, or less than 2,000 feet 

horizontally from, a cloud or when visibility is less than 3 statute miles from the PIC. 

28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an 

ATO issued COA. 

29. All aircraft operated in accordance with this exemption will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be 

as large as practicable. 

30. Before conducting operations, petitioner will ensure that the radio frequency 

spectrum used for operation and control of the UA complies with the Federal 

Communications Commission (FCC) or other appropriate government oversight 

agency requirements. 

31. The UA will remain clear and yield the right of way to all manned aviation operations 

and activities at all times. 

32. The UA will not be operated by the PIC from any moving device or vehicle. 

33. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless one of the following three conditions 

is met: 

A. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The petitioner will ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, the PIC will ensure that flight operations cease immediately. 

B. The aircraft is operated near vessels, vehicles or structures where the owner/

controller of such vessels, vehicles or structures has granted permission and the 

PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present undue hazard. 

C. Operations nearer to the PIC, VO, or essential persons do not present an undue 

hazard to those persons per § 91.119(a). 

Alexis F. Covo - 333 Exemption Petition Page 16 of 24
34. Petitioner will report any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined by the applicable COA 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Petitioner will report 

accidents to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

IX. PRIVACY

There is little concern that the proposed flights will cause invasions of privacy. All flights 

will occur over either (a) public rights of way where there is no expectation of privacy; or 

(b) over private property with permission of the landowner/authorized agent and consent 

of participating individuals.

X. PUBLIC INTEREST AND SAFETY

The planned UA use will increase ground safety for aerial photography, aerial 

cinematography and videography of small events and activities, individual commercial, 

public, and residential properties. 

The enhanced safety and reduced environmental impact achieved using a UA and 

carrying no passengers or crew, rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to 

find that the UA operation enabled by this exemption is in the public interest. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemption, allowing commercial operation of 

petitioner’s UA for aerial photography, aerial cinematography and videography of small 

events and activities, individual commercial, public, and residential properties.

Alexis F. Covo - 333 Exemption Petition Page 17 of 24
XI. REGULATIONS FROM WHICH EXEMPTION IS 

REQUESTED

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command;

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the Alex Covo Photo’ sUAV is remotely 

controlled with no passengers or property of others on board. Section 61.133(a) requires an 

individual with a commercial pilot’s license to be pilot in command of an aircraft for 

compensation or hire.

Alex Covo Photo respectfully proposes that Operator requirements should take into account the

characteristics of the particular UAS. Alex Covo Photo’ sUAV has a high degree of preprogrammed control and various built-in technical capabilities that strictly limit the potential for 

operation outside of the operating conditions set forth in the exemption application.TheAlex Covo 

Photo’sUAV has navigation and control system comprised of aGround ControlStation (GCS) and 

auto-pilot system that can be pre-programmed to set operational boundaries. All flights are preprogrammed with precision GPS guidance.. In the case of unplanned events, the Operator may 

input pre-programmed evasive maneuvers from the control unit, and the onboard autopilot

executes those maneuvers. Pre-programmed Operator interventions include initiation of holding

at present position; suspension of mission; fly back to launch point; abort mission and land 

immediately; and emergencypowercutoffandland(FlightTerminationSystem).

Additional automated safety functions and safety enhancing features of the Alex Covo Photo’

sUAV’smayincludethefollowing:

1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate

landing. 

2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing. 

3. Ifthe auto-pilot detects a lost-link to the ground controller, the UAS will hold position

at its current location for 5 seconds and if the signal is not restored, execute a return to

home and land. 

4. Redundant “kill switches” that enable completely shutting the aircraft down in 

flight in the event of a loss of control or un-commanded deviationfromthe flight

path. 

5. The aircraft, weighs less than 55 lbs., fullyloaded. 

6. The motors are driven by pulse width modulated signals, not analog signals. 

7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) 

nor above 200 feet above the structure (imaging altitude)oramaximum of 400 

AGL. 

Alexis F. Covo - 333 Exemption Petition Page 18 of 24
Given these safety features, Alex Covo Photo proposes that Operators of Alex Covo Photo’s 

UAV should not be required to hold a commercial or private pilot certification.

Instead, Operators should be required to: have successfully completed, at a minimum, FAA 

private pilot ground instruction and passed the FAA Private Pilot written examination or FAArecognized equivalents; have completed the manufacturer’sorAlex Covo Photo’s training 

program for operation of the UAS.

Alex Covo Photo notes that the FAA has found that safety factors permitted operation of UASs 

by Operators with these qualifications in the case of operations pursuant to public COAs where 

the mandatory operating conditions specified above were present. See, Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 

20-21 (July 30, 2013). Likewise, Alex Covo Photo notes that the NPRM does not require that the 

Operator hold a private pilot license issued by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of the Alex Covo Photo’ sUAV without a private pilot’s certificate or a commercial pilot’s

certificate, under the conditions set forthherein.

The risks associated with the operation of theAlex Covo Photo’ sUAV (given its size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the level of risk 

associated with private pilot operations or commercial operations contemplated by Part 61 with 

conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth

above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b)

and does not rise to the level of requiring a commercial pilot to operate the aircraft under §

61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the UAS without

an airworthiness certificate, no standard will exist for airworthiness of the UA. Given the size of the

aircraft and the requirements that the Operator has agreed to as it relates to airworthiness, as

contained in the manual, an equivalent level of safety will be achieved by insuring compliance with

the manuals prior to each flight. The FAAhas granted exemptions to conduct similar operations in

Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority 

to operate at altitudes up to 400 AGL,anexemptionmaybeneededtoallowsuchoperations.

Alexis F. Covo - 333 Exemption Petition Page 19 of 24
The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner, facility owner, and/or local officials. Because of the advance notice to the 

property owner and participants, all affected individuals will be aware of the planned flight 

operations as set forth in the Manuals. Compared to flight operations with aircraft or rotorcraft 

weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented by conventional aircraft 

operating at or below 500 AGL in the aerial photography industry. In addition, the low-altitude 

operations of the sUAS will ensure separation between these small-UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119. The FAA has granted 

exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 

11110.

14 C.F.R. §91.121AltimeterSettings

As discussed in Exemption 11138 is inapplicable since the UAS does not have an altimeter and 

instead utilizes electronic GPS with a barometric sensor for altitude information.

14C.F.R. § 91.151(a):FuelRequirements forFlightinVFRConditions

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day,

to fly after that for at least 30 minutes; or (2)At night, to fly after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet 

the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS’ proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for 

flight is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a)falls within the scope of prior

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed,

with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed of the smallUAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 25% of remaining battery power whichever happens first. This restriction would be 

more than adequate to return the sUAS to its planned landing zone from anywhere in its limited

operating area. Similar exemptions have been granted to other operations, including Exemptions

2689F, 5745, 10673, 10808 and Exemptions 11062, through11067, 11080 and 11110.

Alexis F. Covo - 333 Exemption Petition Page 20 of 24
14C.F.R.§91.405(a);91.407(a)(1);91.409(a)(2);91.417(a)&(b):Maintenance

Inspections

These regulations require that an aircraft Operator or owner “shall have that aircraft inspected

as prescribed in subpart E of this part and shall between required inspections, except as provided

in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the Petitioner. Maintenance will be accomplished by the 

Operator or manufacturer pursuant to the flight manual and operating handbook as referenced in

the Manuals attached as confidential Exhibits An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate

only in defined areas for limitedperiodsoftime.Ifmechanical issuesarise,theUAScanland

immediatelyand will be operating from no higher than 400 feet AGL. As provided in the Aircraft 

Flight Operations Manual the Operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the Operator and manufacturer are most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.The FAAhas

granted exemptions for similar operations in Exemptions 11062 through 11067, 11080 and 11110.

Appendix A-1: 

FARs as to which Petitioner wishes the same determination to be made as has been made

previously (see pages 22-24).

Alexis F. Covo - 333 Exemption Petition Page 21 of 24
FAR

Provision

Applicable condition(s) in 

Section VIII of petition FAA Exemption Decision

21(h) 1, 2, 3, 4, 5, 16, 25, 28, 29 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11111, 11110, 11114, 11136, 11138, 

11150, 11153, 11156, 11157, 11166, 11167, 11170, 

11171, 11172, 11174, 11176, 11177, 11178, 11184, 

11185, 11188, 11189, 11191, 11192, 11193, 11195

43.7 13, 14 No. 11208

43.11 12 No. 11208

45.11 29 No. 11208

45.27 29 No. 11188

45.29 29 Nos. 11136, 11157, 11170, 11185, 11193

91.7(a) 12 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11177, 11178, 11184, 

11185, 11188, 11189, 11191, 11192, 11193, 11195, 

11204

91.9(b)(2) 22 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11157, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11111, 11112, 11114, 11136, 11138, 11150, 11153, 

11156, 11157, 11174, 11177, 11178, 11184, 11185, 

11189, 11192, 11193, 11195

91.9(c) 30 Nos. 11136, 11170, 11171, 11174, 11185

91.103(b)(2) 3, 9, 15, 16, 17, 18, 19, 20 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11138, 11150, 11153, 11156, 11158, 

11160, 11161, 11166, 11167, 11171, 11172, 11176, 

11177, 11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

91.105 6 No. 11185

91.109 7, 8 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11166, 11167, 11170, 11171, 

11174, 11177, 11184, 11185, 11189, 11191, 11192, 

11193, 11194, 11195, 11206, 11208

91.113(b) 3, 31 No. 11238

Alexis F. Covo - 333 Exemption Petition Page 22 of 24
FAR

Provision

Applicable condition(s) in 

Section VIII of petition FAA Exemption Decision

91.119(c ) 4, 33 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 

111109, 11110, 11111, 11112, 11114, 11136, 

11138, 11150, 11153, 11156, 11160 11161, 11166, 

11167, 11170, 11171, 11172, 11174, 11176, 11178, 

11185, 11188, 11189, 11190, 11193

91.121 4 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 

111109, 11136, 11138, 11150, 11153, 11156, 11160 

11161, 11166, 11167, 11170, 11171, 11174, 11176, 

11178, 11185, 11188, 11189, 11190, 11193

91.151(a) 16, 17 Nos. 11110, 11153, 11156, 11161; 111109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11160 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 

11176, 11178, 11185, 11188, 11189, 11190, 11193

91.203

(a) and

(b)

22 Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 

11157, 11170, 11171, 11172, 11174, 11176, 

11177, 11178, 11184, 11185, 11188, 11188, 

11189, 11191, 11192, 11193, 11195

91.215 25, 26 No. 11185, 11195

91.403 12, 13, 14 No. 11185

91.405(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11176, 11177, 

11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

91.407(a)(1) 14 Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11176, 11177, 

11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

Alexis F. Covo - 333 Exemption Petition Page 23 of 24
91.409(a)(1) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11176, 11177, 

11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

FAR

Provision

Applicable condition(s) in 

Section VIII of petition FAA Exemption Decision

91.409(a)(2) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11176, 11177, 

11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

91.417(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11176, 11177, 

11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

91.417(b) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 11176, 11177, 

11178, 11184, 11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 11204

Alexis F. Covo - 333 Exemption Petition Page 24 of 24